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The Centre for Environmental Rights (CER), acting for the Highveld Environmental Justice Network (HEJN), groundWork (gW), and Earthlife Africa (ELA), submitted preliminary objections and recommendations regarding the draft Air Quality Management Plan (AQMP) and draft Air Quality Management By-laws for the Nkangala District Municipality (NDM). The CER argues that the public participation process was procedurally unfair due to insufficient notice and comment periods. Substantively, the CER identifies critical gaps in the draft AQMP, including a lack of enforcement strategies, insufficient technical capacity within the NDM, and misalignment with the Highveld Priority Area (HPA) goals. The CER also proposes significant amendments to the draft by-laws to strengthen dust control, clarify authorization procedures, and ensure stricter local emission standards.

The Centre for Environmental Rights (CER) submitted comments on the revised draft Air Quality Management Plan (AQMP) for the Nkangala District Municipality (NDM). The CER argues that the plan is overly ambitious given the NDM's lack of capacity and resources, fails to align with the Highveld Priority Area (HPA) AQMP, and contains significant technical errors in its air quality modelling and data.